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COLLINS v. COMMISSIONER

Docket No. 11579-90.

64 T.C.M. 557 (1992)

T.C. Memo. 1992-478

Mark D. Collins v. Commissioner.

United States Tax Court.

Filed August 24, 1992.

Attorney(s) appearing for the Case

James B. Lewis, for the petitioner. Raymond A. Kahn, for the respondent.

Memorandum Findings of Fact and Opinion

BEGHE, Judge:

Respondent determined a deficiency in petitioner's 1988 Federal income tax of $9,376, plus additions to tax of $469 under section 6653(a)(1)1 and $2,344 under section 6661.

The issues for decision are whether petitioner had taxable unreported income from gambling or theft during 1988, and whether he is liable for the additions to tax for negligence and substantial...

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